Demonstrating compliance program effectiveness is paramount to successfully and proactively deter and mitigate government enforcement actions. An effective program supports an organization’s response to government and criminal investigations and can ultimately safeguard the organization’s public image, help to reduce fines and penalties, avoid Federal Program Exclusion and/or a Corporate Integrity Agreement.
In 2017, the Office of Inspector General (OIG) issued over 400 metrics for measuring compliance program effectiveness. The same year, the Department of Justice (DOJ) released a series of focused questions that the Fraud Division uses when evaluating a Corporate Compliance Program. DOJ subsequently provided industry additional transparency in 2019 when publishing specific questions by topic and reaffirmed the government’s emphasis on the importance of independent effectiveness reviews.
Our experts at VantagePoint work with both compliance and operational leadership to perform an independent assessment of your compliance program against the 7 elements of an effective program. We examine your program design, operational applications, and whether if works in practice. From there, we collaborate to provide you with a customized action plan to assure optimal results.
Our Compliance program effectiveness assessments include:
Comprehensive Documentation Review
On-site Verification and Interviews
Final Report including an Executive Summary, Detailed Findings and Observations; and Operational Action Plan